Pearson provides a useful summary of these priorities and cautions importers of the prioritized goods “to be prudent to prepare themselves for CBSA trade verifications by conducting internal reviews of their compliance practices, thereby getting out in front of audit results that may include application of administrative monetary penalties.”

Noting also that CBSA audits are random in nature, he cautions that all other importers would be well-advised to do the same.

Good legal advice is essential to this process.

“As business priorities and judgments necessarily colour decisions as to whether or not to become compliant retroactively or prospectively, if at all, it is very important that internal reviews be conducted under the auspices of solicitor-client privilege to retain confidentiality,” Pearson writes. “This is achieved by retaining actual legal counsel; no other professional advisors can offer the same privilege.”